NEW ACT ON THE CENTRAL REGISTER OF BENEFICIAL OWNERS: KEY CHANGES AND OBLIGATIONS FOR REGISTERED ENTITIES

With the implementation of the new Act on the Central Register of Beneficial Owners¹, effective October 1, 2025, registered entities will face a series of new obligations and procedures. Below is a summarized overview of the most important changes, obligations, and deadlines introduced by the new law.

I. OBLIGATIONS FOR EXISTING REGISTERED ENTITIES

Compliance obligation

Existing registered entities are required to comply with the provisions of the law within 60 days from the date the law comes into effect, i.e., by November 30, 2025. In this regard, it is necessary that no later than this date they:

• update or confirm the existing data;
• upload documents based on which the beneficial owner is determined in the Central Register of Beneficial Owners (hereinafter: CESV).

Obligation to record changes

From October 1st on, all changes related to beneficial owners must be recorded in the CESV within 30 days of the change. This includes uploading supporting documents that substantiate the recorded changes.

Obligation to verify and update information

Registered entities are required to verify, update if needed, and confirm the accuracy of the data in CESV at least once a year. This includes:

• Verifying the accuracy and currency of the recorded data within one year from the last data entry or last confirmation;
• Confirming accuracy within 30 days after verification. The Agency for Business Registers will publish a public list of non-compliant entities on its website—those who failed to register or confirm beneficial ownership within the prescribed timeframe.

Consequences of non-compliance

Non-compliance may result in:

• Classification as a high-risk entity;
• Imposition of legal sanctions.

II. SPECIAL OBLIGATIONS FOR AML/CFT ENTITIES

Entities subject to the Law on the Prevention of Money Laundering and Terrorist Financing (AML/CFT Law)—such as banks, investment fund management companies, financial leasing providers, etc.—are required to:

• Obtain beneficial ownership data from the CESV;
• Compare this data with the information collected through AML/CFT measures.

If discrepancies are found or if the data is missing, the AML/CFT entity must immediately notify the competent authority, which will then publish a list of such entities on its website.

III. KEY CHANGES IN THE LAW

Expanded scope of entities

Previously, the obligation to register applied to companies, branches and representative offices of foreign companies, cooperatives, foundations, endowments (and their representative offices), institutions, associations (and their representative offices). Under the new law, the obligation is extended to trusts and similar legal arrangements managed from Serbia or otherwise subject to Serbian jurisdiction.

Expanded grounds for registration

In addition to company formation and changes in ownership structure, the grounds now also include:

• Management of a trust from Serbia;
• Business activities of a trust trustee within Serbia.

Recording Additional Data and Documents

Registered entities are henceforth required to:

• record a greater scope of data about the beneficial owner, including: the legal basis for acquiring the status of beneficial owner, the date of acquiring that status, as well as the date of recording the data and documents;
• upload documents based on which the beneficial owner is determined, as well as a copy of the personal identification document used to verify their identity.

Extended deadline for new entities & ownership updates

The deadline for registering beneficial owners for newly established entities is extended from 15 to 30 days from the registration date, with a requirement to upload relevant documentation. Also, any changes that affect the beneficial owner’s status must be recorded within 30 days of the change.

Sanctions and protective measures

The law introduces three categories of sanctions:

• Criminal liability:
  • Imprisonment from 6 months to 5 years for concealing the beneficial owner, entering false data, deleting correct data, etc.
• Misdemeanor liability (fines):
  • From RSD 500,000 to 2,000,000 for the registered entity;
  • From RSD 50,000 to 150,000 for the responsible individual.
• Protective measures:
  • Prohibition from performing certain activities (for entities) or duties (for individuals) for 6 months to 3 years.

Compliance with the new law requires timely and accurate action by all registered entities. It is strongly advised that entities begin preparing the required documentation as soon as possible.

Disclaimer: The text is informative and does not provide legal advice